Meridian International Center Human Trafficking Policy

In compliance with applicable provisions of 2 CFR § 175, Award Term for Trafficking in Persons, Meridian International Center (“Meridian”) strictly forbids employees, contractors, subrecipients, and its subrecipient’s employees from engaging in human trafficking-related activities. This includes, but is not limited to, the following:

Engaging in trafficking in persons.

Procuring commercial sex acts during the performance of their duties.

Using forced labor.

Using child labor.

Using any individual held in slavery or servitude.

Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses.

Using misleading or fraudulent recruitment practices, such as failing to disclose, in a format and language accessible to the worker, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant cost to be charged to the employee, and, if applicable, the hazardous nature of the work.

Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place.

Charging employees recruitment fees.

Failing to provide, when portions of contracts or subcontracts are performed outside their home country, return transportation or pay for the cost of return transportation upon the end of employment for an employee who is not a citizen of the host country in which the work is taking place and who was brought into that county for the purpose of working on our behalf.

Providing return transportation or paying the cost of return transportation for an employee that is the victim of trafficking, child labor or slavery and is seeking victim services or legal redress in the country of employment, or providing return transportation or paying the cost of return transportation for an employee that is a witness in an enforcement action related to human trafficking, when the return transportation obstructs victim services, legal redress, or witness activity.

Providing or arranging housing that fails to meet the host country housing and safety standards.

Failing to provide an employment contract, recruitment agreement, or similar work document in writing and in a language the employee understands, to the extent such work documents are required by law or contract to be in writing.

Failing to provide an employment contract, recruitment agreement, or similar work document that, to the extent the work documents are required by law or contract to be in writing, does not include details about the work description, wages, prohibitions on recruitment fees, work location(s), living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance process, and the content of applicable laws and regulations that prohibit trafficking in persons.

Failing to provide an employment contract, recruitment agreement, or similar work document to an employee at least five days prior to the employee relocating if the employee must relocate to perform the work and to the extent the work documents are required by law or contract to be in writing.

Meridian requires all employees to support the human rights of others and to abide by this Human Trafficking Policy (“Policy”). Any violation of this Policy may result in employee discipline, up to and including termination of employment. Any violation of this Policy by contractors, subrecipients, or subrecipient’s employees, may result in the termination of their contract or subaward.

Suspected or possible violations of this Policy should be reported directly to any member of senior management or human resources. Any person who has knowledge of or receives information of possible violations under this Policy must notify a member of senior management or human resources immediately. Failure to report such knowledge or information may result in employee discipline, up to and including termination of employment.

All reports will be quickly and thoroughly investigated. To the extent possible, employee confidentiality and that of any witnesses will be protected against unnecessary disclosure. Meridian, however, cannot guarantee that an employee’s statement will never be disclosed, as information sometimes must be shared in order to further an investigation. Also, in the event of legal or administrative proceedings, records and information maintained by Meridian may be subject to disclosure. This confidentiality policy does not restrict employees from discussing matters related to the investigation with coworkers.